Fidelity Title & Trust Co. v. Commissioner
United States Board of Tax Appeals
1. The taxpayer received a letter from the office of the Commissioner of Internal Revenue stating that an examination disclosed an additional tax and, under section 250(d) of the Revenue Act of 1921, he would be granted 30 days in which to file an appeal and show cause or reason why the additional tax should not be paid. Such letter was signed by a Deputy Commissioner.
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1. The taxpayer received a letter from the office of the Commissioner of Internal Revenue stating that an examination disclosed an additional tax and, under section 250(d) of the Revenue Act of 1921, he would be granted 30 days in which to file an appeal and show cause or reason why the additional tax should not be paid. Such letter was signed by a Deputy Commissioner. Held, that such letter does not constitute an assessment. 2. The provisions of the Revised Statutes, so far as applicable, govern the assessment of taxes. Under section 3182 an assessment of tax must be the act of the…
1Opinion of the Court
FIDELITY TITLE & TRUST CO. AND MIRIAM G. HOSTETTER, EXECUTORS UNDER THE WILL OF D. HERBERT HOSTETTER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fidelity Title & Trust Co. v. Commissioner
Docket No. 2795.
United States Board of Tax Appeals
10 B.T.A. 482; 1928 BTA LEXIS 4096;
February 2, 1928, Promulgated
1. The taxpayer received a letter from the office of the Commissioner of Internal Revenue stating that an examination disclosed an additional tax and, under section 250(d) of the Revenue Act of 1921, he would be granted 30 days in which to file an appeal and show cause or reason…
2Cases cited3 opinions
- United States v. FlannerySupreme Court of the United States · 1925
- Art Metal Works v. CommissionerUnited States Board of Tax Appeals · 1927
- Fidelity Title & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1928